WQ0005681_Pilot Study Denial_20221012

October 12, 2022
T INA P EDLEY E NVIRONMENTAL M ANAGER
P ILGRIMS P RIDE C ORPORATION
484 Z IMMERMAN R OAD
S ANFORD, N ORTH C AROLINA 27330
Subject: Permit No. WQ0005681
Pilot Study Denial
Pilgrim's Pride - Staley WWTP
Wastewater Irrigation System
Randolph County
Dear Ms. Pedley:
This letter is in reference to the mechanically-induced evaporation pilot study received June 24,
2022. Per the submitted study (attached), the Permittee proposes a four month pilot study to evaluate the
evaporation efficiency, remote monitoring capabilities, water type compatibility, and energy efficiency of
one Varimax-40 evaporation unit supplied by E3 Solutions.
Division review of mechanically-induced evaporation systems has determined that this process is
not a treatment unit, but a disposal system. Accordingly, any use of a mechanically-induced evaporation
system would require permitting of this disposal option.
However, the Division has determined that since the mechanically-induced evaporation system
aerosolized effluent and the non-gaseous organic and inorganic material contained therein will eventually
deposit onto the land, these systems are not permittable under the 15A NCAC 02T rules because of the
following:
Setbacks cannot be established, maintained, and verified because the aerosolized effluent does
not have a defined land disposal area.
Compliance and review boundaries cannot be established because the aerosolized effluent does
not have a defined land disposal area.
The impacts to human health and the environment from the
other pollutant cannot be evaluated or determined because the aerosolized effluent does not
have a defined land disposal area.
Accordingly, your request for a pilot study has been denied. I have attached a recent memorandum
regarding the use of mechanically-induced evaporation systems for wastewater effluent disposal.

Ms. Tina Pedley
October 12, 2022
Page 2 of 2

If you need additional information concerning this letter, please contact me at [phone] or
[e-mail].
Sincerely,
Nathaniel D. Thornburg, Branch Chief
Division of Water Resources
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche Files (Electronic Copy)

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September 22, 2022
MEMORANDUM
To: File
From: Nathaniel D. Thornburg, Chief Non-Discharge Branch, Division of Water Resources
Subject: Mechanically-Induced Evaporation Wastewater Effluent Disposal (i.e., Zero Liquid Discharge)
Systems
BACKGROUND:
There are many methods by which residential/domestic wastewater is treated and disposed. The North
Carolina Department of Health and Human Services (DHHS) and local health departments have purview
over subsurface disposal systems and the
Division of Water Resources (DWR) has purview -
permitting program and its associated regulations at 15A NCAC 02T are for systems that treat
wastewater and then dispose of the treated effluent via land application. DWR also issues permits under

Recently, DWR has received inquiries as to whether it can issue a permit authorizing an onsite mechanically
induced evaporation wastewater effluent disposal -
discharge wastewater permitting program. Mechanically-induced evaporation wastewater effluent disposal
systems use pumps and high-pressure nozzles to aerosolize treated wastewater effluent. This aerosolized
effluent is injected into a blower-created airstream for evaporative disposal into the air.
OVERVIEW OF -DISCHARGE WASTEWATER PERMITTING PROGRAM AND
REGULATIONS:
-discharge permitting program is premised on the disposal of treated effluent onto a defined
area of land. Accordingly, non-discharge system regulations require that the applicant provide adequate
documentation that the proposed system will meet the design and performance criteria in the regulations,
1
be operated as a non-discharge system, and protect surface water and groundwater standards. The
regulations require that an application contain a site map that identifies, among other things, the disposal
2
area. Once the disposal area is defined, the regulations prescribe specific setbacks from homes, businesses,
3
property lines, water supply wells, and surface waters. The disposal area is also used to establish a
compliance boundary and determines the location where monitoring wells are to be installed to ensure
4
compliance with State groundwater standards for the protection of groundwater drinking supplies.
Applications must also contain a soils report so that DWR can determine hydraulic, nutrient, and other
5
pollutant impacts on human health and the environment. -

1
15A NCAC 02T .0105
2
15A NCAC 02T .0105, .0804, 0504.
3
Id.; see also 15A NCAC 02T .0806 and .0506.
4
15A NCAC 02L .0107 and .0108; see also 15A NCAC 02T .0105.
5
15A NCAC 02T .0105, 0804, and.0504.

Mechanically-Induced Evaporation Wastewater Effluent Disposal (i.e., Zero Liquid Discharge) Systems
September 22, 2022
Page 2 of 3
described in 15A NCAC 02T .0800 must meet these fundamental application requirements, design criteria,
6
and setbacks.
PERMITTING OF MECHANICALLY INDUCED WASTEWATER EVAPORATION EFFLUENT
DISPOSAL SYSTEMS:
As described above, mechanically-induced evaporation wastewater effluent disposal systems use pumps
and high-pressure nozzles to aerosolize treated wastewater effluent into the air. This treatment/disposal
method is not explicitly authorized in -discharge wastewater permitting regulations at 15A
NCAC 02T. DWR has never permitted such a system under any of its wastewater programs, and DWR
does not have any pending applications for such a system. DWR has received information provided by a
manufacturer of the mechanically-induced wastewater evaporation systems.
By its very design, the proposed disposal method will aerosolize the effluent for disposal into the air. The
treated effluent will eventually deposit onto the land, the location and volume depending on countless
variables, both operational and atmospheric (wind, humidity, temperature, etc.). At minimum, the non-
gaseous organic and inorganic material contained within the aerosolized effluent will deposit on an
undefined land surface area. Because the aerosolized effluent does not have a defined (land) disposal area,
DWR cannot establish, maintain, and verify setback requirements, cannot establish the required compliance
boundary, and
pollutant impacts on human health and the environment. As a result, DWR cannot permit the proposed
system under its non-discharge permitting program and its related regulations.
OTHER CONSIDERATIONS:
7
Operation of a wastewater treatment system in North Carolina requires a permit, yet there appears to be no
existing permitting framework to authorize the construction/operation of mechanically-induced evaporation
wastewater effluent disposal systems. EPA approved NPDES permitting program (under the Clean
Water Act and related State laws) requires DWR to ensure that the discharge of treated effluent into surface
waters complies with water quality standards, yet the design of the proposed system does not have a precise
discharge point into surface waters. Similarly, DHHS and local health departments regulate subsurface
systems pursuant to 15A NCAC 18A .1934, yet the design of the proposed system does not dispose of the
wastewater directly into the subsurface.
Please note, this memorandum is for the use of mechanical evaporation methods as a means of dedicated
wastewater disposal and is not intended for natural/passive evaporative disposal systems or mechanical
evaporation treatment systems contained within a closed process.

6
See 15A NCAC 02T .0801, .0804, .0805, .0806.
7
See e.g., N.C. Gen. Stat. §143-215.1

Mechanically-Induced Evaporation Wastewater Effluent Disposal (i.e., Zero Liquid Discharge) Systems
September 22, 2022
Page 3 of 3
-DISCHARGE WASTEWATER PERMITTING REGULATIONS:
15A NCAC 02L .0107 Compliance Boundary
15A NCAC 02L .0108 Review Boundary
15A NCAC 02T .0105 General Requirements
15A NCAC 02T .0504 Application Submittal via 15A NCAC 02T .0804
15A NCAC 02T .0505 Design Criteria via 15A NCAC 02T .0805
15A NCAC 02T .0506 Setbacks via 15A NCAC 02T .0806
15A NCAC 02T .0707 Operation and Maintenance via 15A NCAC 02T .0807
15A NCAC 02T .0708 Residuals Management via 15A NCAC 02T .0808